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Concerning the Use of Animals in Product Safety Testing

A Statement of The Health Protection Branch, Health Canada

The mandate of the Health Protection Branch of Health Canada is to protect the health of all Canadians. It is charged with the responsibility of ensuring the safety and efficacy of drugs, the safety of foods, the safety and efficacy of medical devices, the safety of radiation emitting devices and the safety of certain consumer products. The Health Protection Branch also has the responsibility of drafting legislation designed to protect the public against hazardous substances. The level of safety afforded by this system meets the demands made by the Canadian public for safe and effective products

In order to evaluate a new product for which no safety data exists, it must be tested. Some valid non-animal tests (e.g. tissue culture, biochemical assays) are widely used by the Health Protection Branch and others, as they have proven to be of value in this work. While recognizing the need to further refine, reduce and replace animal use, in the final analysis, new methods can never totally replace testing in an appropriate animal model. For example, in vitro methods cannot show complex interactions of a chemical in a living being. Indeed, the extreme complexity of the biochemical systems in living creatures cannot be duplicated by our current knowledge, nor will it for the foreseeable future

With regard to the much-cited LD-50 test, the Health Protection Branch has not used the classical test as a basis for our regulatory decision-making since 1989. We are, however, aware of the need to assess the acute toxicity of new products prior to their introduction. There is almost universal scientific opinion that in order to determine this, doses must be pushed high enough to cause the death of some animals. In order to minimize this number, toxicity limit tests, which require far fewer animals, have become the standard means of providing this information

The Draize eye and skin irritancy test is, at present, the only reliable means available to evaluate the safety of a substance to be introduced into or around the eye or placed on the skin. The responsibility for the testing of a drug, medical or radiation emitting device, food additive or a consumer product, rests with the manufacturer or producer. The Health Protection Branch monitors the studies undertaken, evaluates manufacturers' submissions prior to granting marketing approval, and conducts post-marketing surveillance of products to ensure that no unexpected problems occur. With respect to cosmetic products, there is no requirement for pre-market approval by the Health Protection Branch. In order to sell such a product, it is sufficient for a manufacturer to have data available to him which shows his products to be safe when used as directed

Studies conducted on behalf of the Health Protection Branch are related to the safety of human health. All projects involving the use of animals, whether the work is performed in our own laboratories or elsewhere, are carefully screened by our veterinarians to ensure every possible measure will be implemented to prevent suffering and to uphold humane standards. The procedures used must be essential to the furtherance of our mandate of protecting the health of all Canadians, there must be no other means by which to gain the required information, and there must be approval by our Animal Care Committee. Compliance with the high standards of animal care and use, administered by the Canadian Council on Animal Care, is required by all major granting agencies and government departments.

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